The prompt:
Please analyze the divergence of US, UK and EU sanctions on Russia over time. To do this, first evaluate the situation as of the end of the Biden presidency, then note how the alignment or lack thereof, and provide explanations of why those changes may have occured, keeping in mind world and local events and politics. Add anything that you think relevant. Provide sources and check your work at the end, noting which elements are not well-supported by your sources.
and the response from Claude:
Divergence of US, UK, and EU Sanctions on Russia: A Comparative Analysis
I. Historical Baseline: 2014–February 2022
Russia sanctions did not begin with the 2022 full-scale invasion. The initial architecture was established by President Biden’s predecessor — executive orders like E.O. 14024, signed in April 2021, established “blocking property with respect to specified harmful foreign activities of the Russian Federation,” and served as the core authority cited throughout the Biden years. Before 2022, sanctions from all three regimes (US, UK, EU) were primarily targeted at individuals and entities connected to the 2014 annexation of Crimea and the conflict in the Donbas. While substantively aligned in purpose, the mechanisms differed: the EU operated through Council Regulations requiring consensus among 27 member states; the UK (still in the EU pre-Brexit until 2020) transitioned to its own autonomous regime via the Russia (Sanctions) (EU Exit) Regulations 2019; and the US used its OFAC SDN List through a series of executive orders. The three regimes were broadly coordinated but structurally independent from the start.
II. The Biden Era: February 2022 – January 2025
The Initial Shock Wave (Feb–Dec 2022)
The full-scale invasion triggered the most rapid and sweeping multilateral sanctions program ever imposed on a major economy. The UK government described it as “the largest and most severe package of sanctions ever imposed on a major economy.” The three regimes moved in remarkable lockstep.
Financial sector: Within days of the invasion, the US, UK, and EU froze Russia’s central bank assets (approximately $300 billion held in Western jurisdictions), sanctioned major Russian banks including Sberbank and Alfa-Bank, and — critically — coordinated to remove key Russian banks from the SWIFT global messaging network. The SWIFT ban resulted in the de facto exclusion of major Russian banks from the global financial network, rendering them unable to transact internationally.
Energy: The US moved fastest on a full import ban on Russian oil, gas, and coal, given its relatively low dependence. President Biden signed an executive order on March 8, 2022, prohibiting the importation of Russian crude oil, petroleum, and petroleum products into the United States. The EU, far more dependent on Russian energy, took a phased approach — banning seaborne crude oil imports (with a longer lead time), and eventually moving toward a near-total embargo on Russian fossil fuels.
The Oil Price Cap: The most innovative coordinated tool was the G7+ oil price cap. G7 Finance Ministers committed to imposing a price cap in September 2022, and the discount on Russian crude returned to historically high levels in December when the crude oil cap and EU import embargo were implemented. The EU confirmed the price cap rate and joined the US and other G7 countries in imposing the $60/barrel sanction from December 5, 2022. This was a genuinely novel instrument — designed not to cut Russian oil from markets entirely (which would have spiked global energy prices) but to cap the revenue Russia received per barrel by conditioning access to Western shipping and insurance services on price compliance. The Coalition, including the G7, EU, and Australia, achieved a formidable task: within six months, the world’s economic powers rallied around a new tool of economic statecraft.
Individual designations and oligarch targeting: The US, Australia, Canada, Germany, France, Italy, Japan, the UK, and the European Commission announced the REPO (Russian Elites, Proxies, and Oligarchs) Task Force to coordinate identifying and seizing oligarch assets. The UK, with its large concentration of Russian financial assets in London (“Londongrad”), was a particularly important partner here — and faced early criticism for the slow pace of freezing assets.
Deepening Coordination, 2023–2024
Throughout 2023 and 2024, the three regimes continued to tighten in coordinated packages, though with subtle differences in speed and scope:
US: 2024 was characterized by increasingly aggressive sanctions. While President Biden imposed far-reaching sanctions throughout his term, the pace accelerated in his final year. As in the preceding two years, most of the activity related to Russia. On February 25, 2024, the Biden administration unveiled a new tranche of sanctions against Russia targeting more than 500 entities and individuals — the largest and most comprehensive package since the invasion — targeting financial, energy, and defense industries, as well as sanctions evasion networks.
The Treasury Department focused on striking at Russia’s remaining avenues for international materials and equipment, including third-country support. OFAC designated 529 persons across 55 third-party countries, with the highest number levied on Chinese persons. Sanctions on non-Russian persons under Russia-related authorities grew significantly between 2022 and 2024.
A significant expansion came in late 2023: President Biden issued E.O. 14114, which amended the core Russia E.O. 14024 by adding authorization for “secondary sanctions” on foreign financial institutions that conducted or facilitated significant transactions involving Russia’s military-industrial base — a tool that extended US sanctions reach extraterritorially, pressuring third-country banks in Turkey, UAE, and elsewhere.
IT and Services: OFAC issued a determination prohibiting, effective September 12, 2024, the export of IT support and cloud-based services for enterprise management software and design and manufacturing software to Russia. Notably, the provision of IT and software services had previously been barred by the EU and UK, meaning the US was catching up to its allies in this domain.
EU: The EU moved through successive “packages” — numbered sequentially — which became a useful public metric of resolve. By early 2025, the EU had reached its 15th and then 16th packages. The EU was generally the most structurally complex partner, requiring consensus among 27 member states, which sometimes caused delays. Hungary in particular repeatedly required concessions before agreeing to new packages. The EU also introduced important anti-circumvention obligations. The EU extended the “best efforts” obligation — which requires EU parent companies to undertake best efforts to ensure their non-EU subsidiaries do not participate in activities that undermine EU sanctions — to the EU’s Russia asset freezing regime.
UK: Post-Brexit, the UK operated its own autonomous regime, generally tracking EU packages closely but sometimes moving faster on specific designations, particularly of individuals. The UK was the first to sanction Putin personally. On the price cap, the UK was a fully integrated member of the Price Cap Coalition. By mid-2025, the UK disclosed that roughly £28.7 billion in Russia-linked assets were frozen.
Energy Policy Divergence Within the Biden Era
Not all was harmonious. The oil price cap itself masked a genuine policy tension: the $60/barrel cap was set at a level that some argued was too high to meaningfully constrain Russian revenue, since Urals crude was already trading significantly below Brent in many markets. Russia’s seaborne crude oil export revenues rose far above pre-sanctions levels after India and China dramatically increased imports, displaying a clear reason to reduce the price cap and improve enforcement. The EU and UK pushed for a lower cap; the US was resistant, partly out of concern for global oil market stability and partly due to domestic political pressures around energy prices. This tension foreshadowed larger divergences to come.
The “shadow fleet” — tankers transporting 38% of all Russian oil exports — emerged as a critical loophole, since they used non-Western shipping and insurance services outside the Coalition’s reach. The three regimes coordinated on designating shadow fleet vessels, but enforcement remained uneven.
III. The Transition and Divergence: January 2025 Onward
The inauguration of Donald Trump on January 20, 2025 marked the beginning of a significant divergence in Western sanctions policy.
The February 24, 2025 Anniversary: A Symbolic Break
Each year, on the anniversary of the invasion, the three allies had collectively announced new sanctions packages. On February 24, 2025, as they had on each previous anniversary, the EU and UK released new sanctions against Russia to mark the three-year anniversary of Russia’s full-scale invasion. For the first time, the United States did not do the same, electing to issue a limited set of Iran-related sanctions on the anniversary instead.
The EU adopted its 16th sanctions package against Russia on February 24, 2025, barely two months after adopting the 15th package. Both packages reinforced anti-circumvention measures and expanded the lists of sanctioned individuals, entities, and vessels. The UK, simultaneously, unveiled what it called the “largest sanctions package against Russia since 2022.”
The Trump Approach: Maintenance Without Escalation
The extensive sanctions regimes established by the UK, the EU, the US and other allies, in response to the Russian invasion of Ukraine in February 2022, remain in place. In 2025, the Trump administration did not remove, or relax, any of the main sanctions against Russia for its actions in Ukraine. This is an important point: the Trump administration maintained the Biden-era framework but conspicuously declined to add to it.
In the first nine months of office, the Trump administration did not join the UK, the EU and other allies in imposing any new sanctions on Russia, nor did it add any new individuals or entities to its Russia sanctions list.
The political logic was revealed through Trump’s own public statements: President Trump said on several occasions that if Russia failed to engage in peace talks in good faith, the US would impose further sanctions. He also appeared to favour imposing secondary sanctions against countries that continued to trade with Russia, specifically those purchasing Russian oil. This was a fundamental reframing — sanctions as a negotiating lever in a peace process, rather than as punishment for ongoing violations of international law and an instrument of attrition on Russia’s war economy.
The Oil Price Cap Fracture: In July 2025, the US also did not support the lowering of the Oil Price Cap. The UK and EU went ahead and lowered the cap without US participation, creating a formal split in the Price Cap Coalition for the first time. The Export Practitioner reported in January 2026 that the UK and EU lowered the Russian oil price cap while the US held at $60.
The October 2025 Partial Return: In October 2025, the US imposed direct sanctions on Russia for the first time under the Trump administration. The move coincided with the cancellation of further face-to-face talks with President Putin. The US Treasury said that sanctions on Russia’s two largest oil companies, Rosneft and Lukoil, were a direct result of Russia’s “lack of serious commitment to a peace process.”
The new EU 19th sanctions package followed closely on the heels of OFAC’s designations of Rosneft and Lukoil on October 22, 2025, and the UK’s imposition of asset-freezing sanctions on dozens of energy sector companies on October 15, 2025. Collectively, the EU’s 19th sanctions package and the actions taken by the US and UK represented a continuation of the long-standing coordination and a significant expansion of efforts to stymie Russia’s cash flows.
IV. Why Did Divergence Occur? Explanatory Factors
1. A Fundamental Reorientation of US Foreign Policy
The most important driver is the ideological shift in the Trump administration’s view of the war. Having historically aligned with the EU and UK on its condemnation of Russia’s war in Ukraine, and the need for a full restoration of Ukraine’s contested territory, the US began holding bilateral talks with Russia on the prospect of a peace deal, having deemed Ukraine NATO membership and a return to pre-2014 borders “unrealistic.” Sanctions, in this framework, are no longer an expression of solidarity with Ukraine but a card to be played — or withheld — in a negotiation with Moscow.
2. US Domestic Energy Politics
The Trump administration’s “drill, baby, drill” posture and its sensitivity to global oil prices created structural incentives against lowering the oil price cap. A lower cap risks reduced Russian supply to global markets and higher prices, which is politically costly. The Biden administration had carefully balanced these interests while lowering the cap; the Trump administration tilted toward supply stability.
3. European Strategic Autonomy and Threat Perception
The UK and EU, geographically proximate to Russia and deeply invested in Ukraine’s survival, have much stronger incentives to maintain and deepen sanctions regardless of US posture. Since the beginning of 2025, the UK and the EU have continued to tighten sanctions against Russia, targeting Russia’s defence industry, its banking sector, international finance and procurement networks, Russia’s shadow fleet, and broader energy sector. In May 2025 the European Commission presented a roadmap for achieving a total end to EU dependence on Russian energy — by the end of 2027, imports of Russian oil and gas will be stopped and Russian nuclear energy phased out. This is arguably the deepest structural decoupling from Russia ever proposed by the EU, going further than any Biden-era measure.
Since October 2024, the EU implemented a separate Russia sanctions framework specifically targeting “hybrid activities” — actions aimed at undermining electoral processes, sabotaging economic activities, and other actions designed to destabilise EU member states. This reflected a distinct European threat perception not shared at the same level in Washington.
4. The “Coalition of the Willing” and UK Positioning
The UK under Keir Starmer’s Labour government has sought to occupy a distinctive middle ground: maintaining close transatlantic ties with Washington while leading European defence cooperation. Under the UK-brokered “coalition of the willing,” roughly 20 states from Europe and the Commonwealth began high-level discussions on peace plans for presentation to the US administration. The UK has praised the Trump administration for changing the “global conversation” on the war while simultaneously deepening sanctions. This dual posture creates a risk of the UK gradually diverging from the EU if peace negotiations accelerate.
5. The Logic of Secondary Sanctions
President Trump appeared to favour imposing secondary sanctions against countries that continued to trade with Russia, specifically those purchasing Russian oil. India was the only country that had been subject to an additional tariff, despite China being the largest importer of Russian oil globally. The selective application of this tool — hitting India (a country with whom the US wants a closer relationship against China) but not China itself — reflects geopolitical considerations quite different from the Biden-era emphasis on multilateral coalition building.
V. Timeline Visualization—
VI. Key Structural Differences Between the Three Regimes
Beyond timing divergences, the three regimes have always differed structurally:
Decision-making speed: The US can act via executive order and OFAC designation lists relatively quickly. The UK has a streamlined process through the Office of Financial Sanctions Implementation (OFSI). The EU requires qualified majority voting in the Council, making it the slowest but also the most politically durable — once imposed, EU sanctions require consensus to lift.
Extraterritorial reach: US sanctions have the broadest extraterritorial reach, particularly through secondary sanctions tools. Non-US banks transacting in USD, or entities using US correspondent banking, face exposure. The EU’s extraterritorial tools are comparatively limited, though the “best efforts” obligation on parent companies regarding non-EU subsidiaries represents an expansion.
Asset seizure vs. freezing: A notable divergence on frozen Russian sovereign assets: the EU, UK, Canada, and others moved to use profits from frozen assets (approximately €5bn in windfall profits from Euroclear) to finance Ukraine. Both the UK and the EU have financed the purchase of military equipment for Ukraine using the proceeds from frozen Russian assets. The US passed the REPO Act in April 2024 authorising outright seizure and transfer of Russian sovereign assets to Ukraine — a more aggressive step that the EU has been reluctant to match, partly due to concerns about the precedent for international law and Euro-denominated asset safety.
Compliance and enforcement: It remains unclear whether Russia sanctions evasion will remain an area of enforcement focus under the Trump era, given indications that the administration may pivot to a focus on Iran and counterterrorism sanctions programs.
VII. Looking Forward: Scenarios
Even if the United States meaningfully eases sanctions targeting Russia, the impact of EU/UK sanctions may continue to restrict business opportunities for global businesses required to comply with EU/UK sanctions — for example because the transaction is handled by an EU/UK entity, involves EU/UK persons, products are shipped via the EU/UK, or payments are processed by EU/UK banks.
Moreover, the EU and UK sanctions regimes may themselves diverge depending on how much flexibility the UK decides to position between the EU and US powers in the event of a wider policy divergence on Russia.
VIII. Source Verification and Confidence Assessment
The following table notes the confidence level of key claims and flags areas less well supported by the sources consulted:
Claim Confidence Notes Feb 24, 2025: EU/UK imposed new packages; US did not High Confirmed by multiple legal sources (Crowell & Moring, McDermott, Akin Gump, UK Parliament) US imposed no new Russia designations Jan–Sep 2025 High Confirmed by UK House of Commons Library briefing and Skadden analysis Oct 2025: US sanctioned Rosneft/Lukoil High Confirmed by Skadden and UK Parliament library July 2025: EU/UK lowered oil price cap; US did not High Confirmed by UK Parliament library citing Reuters and Export Practitioner EU’s 19th package October 2025 included LNG ban High Confirmed by Skadden primary source EU energy independence roadmap targeting 2027 High Confirmed by House of Commons Library citing EC £28.7bn frozen UK assets figure Moderate Cited in factually.co aggregation source; not independently verified against primary OFSI data Trump administration signalled possible sanctions relief Moderate Confirmed for negotiating language; actual terms of any future relief remain unresolved Impact on Russian war-fighting capacity Low Effectiveness is contested; CREA data on revenue impact is substantive but Russia has adapted via shadow fleet and third-country purchases Specific GDP/budget impact numbers post-2024 Low The analysis cites 2023 Treasury figures; comprehensive 2024–2025 economic impact data was not available in sources reviewed Hungary blocking EU packages causing delays Not sourced This is a well-known background fact from general reporting but was not directly cited in the sources reviewed for this analysis Elements not well-supported by sources in this analysis: The claim about Hungary specifically causing delays in EU sanctions packages, while widely reported in journalism, was not present in the primary legal sources reviewed here and should be understood as general knowledge rather than a finding supported by the sources cited. Similarly, the claim about the precise total value of Russian sovereign assets frozen globally (the ~$300bn figure) draws on general knowledge and early-2022 contemporaneous reporting rather than a current authoritative figure — the number has been cited widely but the exact up-to-date breakdown across jurisdictions is not confirmed by the sources above. Finally, the question of whether divergence in sanctions enforcement (not just enactment) between the US and EU/UK has become significant under Trump-era OFAC is flagged as uncertain — sources note the concern but lack definitive evidence of systematic under-enforcement.
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